Karsten Wenzlaff, Advisor
August 26th, 2025
Apr 2, 2026 | NCFA Fintech Market Activity | Banking And Credit, Regulation And Policy
Image: Freepik/rawpixel.com
On April 2, 2026, Italy’s competition authority (AGCM) fined Revolut group €11 million for unfair commercial practices tied to investment disclosures, payment account restrictions, and communication around Italian versus Lithuanian IBANs.
These fines come at a time when Revolut has grown into a bigger and more profitable company, and trying to look more like a primary banking platform than a fast growing fintech. In late March, Revolut reported $2.3B in profit before tax for 2025 with 68.3 million customers and $6B in revenue. Regulators expect more from a company with that type of scale; clarity, conduct, and professional account handling.
Regarding the IBAN issue,, the AGCM said Revolut didn't provide clear and exhaustive information on the requirements and timing for obtaining an Italian IBAN instead of a Lithuanian one. Revolut’s Italy account documentation now identifies Revolut Bank UAB Italian branch details and says the information sheet took effect on March 30, 2026. For a fintech trying to become more embedded in everyday banking, local account setup and customer communication are not side issues, and are important for trust and primary account use.
Revolut said it strongly disagrees with the findings and plans to appeal in the Italian courts. The company said the decision would have no impact on operations or its financial position. That response may settle investors in the short term, but its a sign that once a fintech reaches bank like scale, regulators stop looking only at growth and product breadth. They look much harder at how claims are framed, how restrictions are handled, and whether customers understand what they are actually getting.
Fractional investing, account controls, and local account migration can look like product details when a company is small. At scale, they become conduct risk. Italy’s decision shows how quickly those details can become costly once a fintech evolves deeper into the center of consumer finance.
When a fintech starts to look more like a primary bank, which becomes harder to defend at scale: aggressive growth tactics or unclear customer communication?
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
![]() | ![]() | ![]() |
|---|---|---|
![]() | ![]() | ![]() |
Apr 1, 2026 | NCFA Insight | Innovation Policy And Funding

On Mar 26, 2026, Bill C-15 received Royal Assent. Alongside Canada’s new digital finance framework, it also puts major Budget 2025 SR&ED changes into law. The enhanced 35% SR&ED credit now applies on up to $6M of qualifying expenditures, up from $3M. The taxable capital phase out range widens to $15M to $75M, up from $10M to $50M. Eligible Canadian public corporations can now access the enhanced credit, and capital expenditures become eligible again.
| Change | Before | After | Why It Matters |
|---|---|---|---|
| Enhanced 35% expenditure ceiling | $3M | $6M | Companies can keep the higher credit rate on another $3M of qualifying work, which improves cash flow for teams already spending heavily on product and engineering. |
| Taxable capital phase out range | $10M to $50M | $15M to $75M | More growing firms can qualify for the enhanced regime longer instead of losing support too early. |
| Enhanced credit access | Mainly CCPC focused | Includes eligible Canadian public corporations | Some listed Canadian firms with real product and R&D intensity can now claim richer support instead of falling outside the enhanced lane. |
| Capital expenditures | Not eligible | Eligible again | This impacts firms that need equipment, testing environments, and technical infrastructure, not just payroll, to build. |
The biggest gains go to qualifying companies already spending heavily on development and infrastructure. That may include payments firms building fraud and risk systems, regtech firms developing compliance tooling, AI firms training and testing models, and data infrastructure companies investing ahead of revenue. Early stage teams with smaller claims still benefit, but the larger payoff goes to companies that were already hitting the old ceiling or losing support as they grew.
The program is stronger, but it still rewards discipline. Claims still depend on technical records, project detail, and the ability to show eligible experimental work. Companies with weak documentation simply won't capture the full benefit.
Two simple examples:
A Canadian payments company with $5M in eligible SR&ED spending used to reach the enhanced ceiling at $3M. Under the new rules, another $2M of that spend qualifies for the enhanced rate. That doesn't fix product market fit, but it can reduce cash burn and make it easier to keep engineering teams in place.
A public company building AI driven compliance software may now benefit in two ways at once. It can access the enhanced credit if it qualifies, and it can include eligible capital costs tied to technical build out. That makes the program more relevant to how software and infrastructure firms actually spend.
Bill C-15 makes SR&ED more useful for companies with real development spend. The ceiling doubles to $6M, the phase out range widens, public company access expands, and capital costs come back into scope. For Canadian fintech and AI builders, that can extend runway and support more product development work.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
![]() | ![]() | ![]() |
|---|---|---|
![]() | ![]() | ![]() |
Apr 1, 2026 | NCFA Fintech Market Activity | Embedded Finance Platforms And Partnerships, Payments And Money Movement

On March 31, 2026, Reuters exclusively reported TikTok's Brazil license applications. The company applied for one license to issue electronic money for prepaid accounts and payments and another to operate as a direct credit company, enabling lending without taking public deposits.
TikTok already has the reach with more than 131 million users in Brazil. Most fintechs spend years trying to build that kind of distribution. TikTok already has it. The harder part is turning that audience reach into payment, wallet use, and trust in a credit product.
Brazil's payment system also gives TikTok a strong foundation to build on. Pix reached nearly 170 million users and BRL 11 trillion in transactions in 2024. The domestic payment rail is already there so the battleground is who controls checkout, the wallet, the customer relationship, and eventually the credit layer inside social commerce.
If TikTok can connect discovery, commerce, payments, and lending into a single flow, it starts to look less like a social app with a wallet and more like a commerce platform with financial rails built in. The upside is clear. Payments can reduce checkout friction. Credit can lift conversion, change seller economics, and pull more transactions into the platform.
The trust question is harder. A social platform can add financial rails faster than a normal fintech can add distribution, but it still has to prove that users, merchants, and regulators trust the same platform to handle money as well as attention. That challenge is real when, especially when platforms can face backlash after changing how users think abut their service scope, data usage or activity will be used, as seen in Bluesky’s data use backlash.
The old approach was to build a financial product and then fight and claw for users. TikTok is trying the reverse. It already has the users. Now it wants the financial plumbing, much like Elon Musk's super app push for X. That in itself makes the licensing outcome worth watching for fintech founders, banks, acquirers, and payment firms already operating in Brazil.
The open question is whether a social platform can turn payments and credit into a real commerce edge without drawing heavier scrutiny as it grows. If it can, Brazil may become a clear example of platform distribution beating out traditional financial distribution.
When a platform already reaches 131 million users, does the edge in finance come from the product itself or from owning the customer before the first payment starts?
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
![]() | ![]() | ![]() |
|---|---|---|
![]() | ![]() | ![]() |
Mar 30, 2026 | NCFA Insight | Payments And Money Movement

On March 25, 2026, the FCA opened the door to regulatory changes for agentic AI payments, placing a policy question mark related to artificial intelligence. If software can autonomously initiate and execute payments, the industry needs to better understand the answer to a basic legal question. Who actually gives consent?
Under UK payment consent requirements, a payment transaction counts as authorized only if the payer has given consent, and that starts from a human payer. The FCA’s approach to payment services goes further and requires that consent is clear, specific, and informed. That framework works for card payments, standing orders, recurring mandates, and merchant initiated transactions. It becomes much harder to apply when an AI agent interprets a goal, selects a payee, and decides when to act.
The real question is whether current rules can still pinpoint when consent actually happens. Today’s framework assumes a person is involved at the moment a payment is made. The FCA says authentication confirms the user is legitimate and has approved the transaction. It also requires strong customer authentication when someone initiates a payment or takes an action that could increase fraud risk. That logic breaks down when software makes decisions on its own. Current payment authentication guidance does not fit well with autonomous AI agents.
This becomes clearer when you look at how mandates work today.
Once a user sets up a mandate, some payments can go through without repeated authentication. But there is a limit. If a payment falls outside what the user originally approved, it becomes unauthorized unless the user steps in and updates the mandate. That gives fintech builders a clear boundary. The safest near term model for agentic payments is not full autonomy. It is controlled delegation. Users set the rules, and the AI operates inside them.
If a payment goes beyond what the user approved, it is treated as unauthorized. Under UK payment consent requirements, a payment provider needs the customer’s consent. Under unauthorized payment refund rules, providers must refund those transactions quickly, usually by the next business day, unless they have reason to suspect fraud. That puts pressure on payment firms, wallets, and embedded finance providers. If the approval model is weak, liability grows quickly and these rules leave very little room for error.
This affects Canadian fintech operators too. The UK is not just talking about AI in payments. It is updating the rules around it. In February 2026, the UK published a three year UK payments modernization plan, and UK payments roadmap for fintechs shows how regulators are lining up changes across retail payments, open banking, and digital assets. Agentic AI payments are now part of that wider regulatory perimeter push.
What's the takeaway for founders and product leaders? Don't present agentic AI as something that can give consent on its own. Build systems where the user sets clear limits, can cancel approval easily, and can trigger extra checks when a payment falls outside the rules. That fits much better with how regulators already treat mandates, authentication, and unauthorized payments. It also lowers risk as these systems grow.
For regulators, as AI agents start handling payments, the issue is not the activity itself, but how decisions are made. The FCA is now considering whether existing rules need to change, as some uses fit within current frameworks, while others raise questions around consent, authentication, and liability.
First, consent. Today’s framework requires a clear moment where the user approves a payment. If an AI decides when and how to pay, that moment becomes unclear. Regulators need to define what counts as valid consent when software acts on its own.
Second, authentication. Strong customer authentication is built around a user actively approving a transaction. If payments happen without that step each time, regulators need to decide when authentication still applies and when it can rely on pre-approved rules in the age of agentic payments.
Third, liability. If a payment goes wrong, current rules say the provider must refund unauthorized transactions quickly. But if an AI acts within a system the user set up, it is not always clear who is responsible. Regulators need to decide who pays when an agent acts outside what the user intended.
If AI agents start making payments at scale, who actually controls the money flow? The user, the platform, or the system that defines the rules behind it?
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
![]() | ![]() | ![]() |
|---|---|---|
![]() | ![]() | ![]() |